/ January 24, 2017
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USGC GulfstreamProject
The Dow Chemical Company

Gulfstream Cooling Tower Fire Prevention Plan

Introduction / This document describes the actions required for all cooling towers under construction on the Gulfstreamconstruction sites.
Application / Actions apply to all cooling towers under construction on the Gulfstreamconstruction sitesonce the fill is installed.
Emergency Response / Dow Emergency Services and Security will provide emergency response for cooling tower events.
Requirements / See list below of requirements which must be followed.
Step / Description
1 / Construction work should be planned in such a way that no hot work will be performed on the cooling tower after the fill is installed.
2 / If hot work is required on a cooling tower once the fill is installed, the hot work will be treated as high energy hot work in a flammable areadue to the combustibility of the fill. This includes:
  • Each hot work job will be issued an individual high energy hot work permit

  • Each hot work job will require secondary approval prior to the start of the hot work

  • Each hot work job will be required to have a separate fire watch

  • Each hot work job will be required to have a fire extinguisher within 25 feet

  • Each hot work job will have all personnel cleared from the hot work area except those involved in the hot work

  • Each hot work job will have flammables cleared from the work area i.e. gasoline cans, gas cylinders, etc. prior to the start of the hot work

  • Each hot work job will have spark containment in place i.e. fire proof tarps, wetting of material, wetted tarps, etc. to prevent the spread of hot material

  • Each hot work job will ensure the fire watch understands their responsibilities, is equipped to notify emergency response personnel, is a separate person from the one doing the work, and has no other job assignment as long as the hot work is active

  • Each hot work job will require the fire watch to remain at the hot work location 30 minutes after the hot work has stopped to ensure smoldering does not occur leading to a fire

Continued on next page

Gulfstream Cooling Tower Fire Prevention Plan, Continued

In addition, the following requirements will be met.

3 / Flammable materials will not be left unattended or stored within 35 feetof a cooling tower.
4 / High energy temporary lighting will be removed.
5 / All portable equipment such as welding machines, portable generators, air compressors, light towers, etc. will be shutdown at the end of each work shift.
6 / Construction vehicle parking (trucks, gators, etc.) will be minimized near cooling towers.
7 / Wooden scaffolding material will not be stored next to cooling towers except for material being staged for installation on the same day.
8 / Combustible material will not be stored within 35 feet of cooling towers.
Revision history / The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.
Date / Revised By / Changes
5/26/2015 / Mary Schwartz / Document created.
1/24/2017 / Mary Schwartz / Clarification made to type of hot work. This was the intent all along but was not clear.

GulfstreamCooling Tower Fire Prevention Plan This is a controlled document. No un-authorized modifications.

Health, Safety, and Environmental